National Mines and Allied Workers' Union vs. Valero

Factual Background

Camarines Norte Mahogany Co., Inc. was engaged in the export of logs and maintained a log pond at Mercedes, Daet, Camarines Norte. The members of NATIONAL MINES & ALLIED WORKERS' UNION (NAMAWUMIF) at Mercedes were dock workers and stevedores who performed loading operations at the port. On May 20, 1970 the union requested recognition as exclusive bargaining representative and preferential employment for its members. The company refused, stating that it had authorized the Mercedes Arrastre to perform loading. On May 23, 1970 petitioner and Philippine Island Arrastre executed an agreement recognizing the union as sole bargaining representative for loading operations; petitioner asserted that Philippine Island Arrastre was respondent's contractor.

Disputed Events at Port and Lower Court Pleadings

On June 2, 1970 the vessel "Dai Leung" arrived to load respondent company's logs. On June 2 petitioner filed a notice of strike with Region 6 of the Department of Labor and thereafter prevented the loading of logs to the vessel. On June 3, 1970 respondent company filed a verified complaint for injunction in the Court of First Instance alleging lack of privity with the union, threats and force by union members that prevented loading, and daily demurrage losses of Eight Hundred Dollars ($800.00) or about Four Thousand Eight Hundred Pesos (P4,800.00). On the same date the trial court issued an ex parte writ of preliminary injunction enjoining petitioner from preventing loading on "Dai Leung". Respondent company posted a cash bond of Three Thousand Pesos (P3,000.00).

Post-Injunction Motions and Modification

Petitioner filed motions for reconsideration and for recall of the writ and moved for dismissal on the ground that the controversy was a labor dispute within the jurisdiction of the defunct Court of Industrial Relations. On June 9, 1970 respondent moved to amend or modify the writ to cover any vessel arriving to load the company's logs. On June 18, 1970 the court denied petitioner's motions, held that no privity of contract existed between petitioner and the company and therefore no unfair labor practice had been committed, and modified the injunction to restrain petitioner from preventing loading to any vessel at Mercedes during the pendency of the action. By order dated July 8, 1970 the court declared petitioner in default for failure to file an answer and permitted respondent to present evidence before the branch clerk of court.

Issues Presented to the Supreme Court

The petition for certiorari and prohibition raised two principal questions: whether the respondent judge acted without or in excess of jurisdiction in issuing and modifying the preliminary injunctions, and whether the controversy fell within the jurisdiction of the former Court of Industrial Relations under Republic Act No. 875.

Petitioner's Contentions

Petitioner argued that the June 3, 1970 writ of preliminary injunction was issued without notice or hearing and thus violated due process. Petitioner further maintained that the dispute was a labor controversy within Section 2(j) of Republic Act No. 875, because the controversy concerned representation and conditions of employment even absent a strict employer-employee relation, and therefore cognizable by the Court of Industrial Relations. Petitioner relied on alleged prior conciliation by Region 6 of the Department of Labor and on the May 23, 1970 agreement between it and Philippine Island Arrastre as evidence of privity or of a labor relationship.

Respondent Company's Contentions and Trial Court Justification

Camarines Norte Mahogany Co., Inc. denied any employer-employee relationship or authorization of Philippine Island Arrastre to act as its agent in recognizing the union. Respondent asserted that the verified complaint and affidavits established that great and irreparable injury would result from delay because of demurrage charges, thereby justifying an ex parte preliminary injunction under Section 5, Rule 58. Respondent emphasized that it had posted bond to secure any damages that petitioner might sustain if the injunction proved wrongful.

Supreme Court's Findings on the Preliminary Injunction

The Court held that the issuance of the June 3, 1970 writ of preliminary injunction was not improvident. The Court applied Section 3 and Section 5 of Rule 58 and reasoned that the verified complaint contained sufficient allegations that respondent would suffer great and irreparable injury from continued obstruction of loading, given the daily demurrage exposure of Eight Hundred Dollars ($800.00) and the factual allegation that union members used force and threats to prevent loading. The Court noted that Rule 58 permits ex parte issuance where affidavits or a verified complaint demonstrate that delay by notice would render relief ineffective. The Court also observed that respondent posted a P3,000.00 bond. The Court further found that petitioner was not deprived of due process because it filed urgent motions for reconsideration and supplemental pleadings that fully presented its arguments to the trial court.

Supreme Court's Findings on Jurisdiction

The Court rejected petitioner's contention that the matter was within the exclusive jurisdiction of the Court of Industrial Relations. The Court reiterated its settled test for CIR jurisdiction under Republic Act No. 875 as articulated in prior decisions: jurisdiction attaches only where (a) an employer-employee relationship exists between the parties or the claimant seeks reinstatement, and (b) the controversy falls within specified subject matter categories such as cases certified by the President as involving national interest, unfair labor practice charges, or claims under the Eight Hour La